Document

Privacy Policy

Last updated: 5 October 2026

This notice explains how the personal data of users of workshopfotografico.com is processed, pursuant to Regulation (EU) 2016/679 («GDPR») and Italian Legislative Decree 196/2003.

1. Data controller

The data controller is Massimiliano Uccelletti (hereinafter «MaXu»; VAT 09470951006), based at Viale Stefano D'Arrigo 79, 00131 Rome (Italy). For any matter regarding your data you may write to maxu@workshopfotografico.com.

2. What data we collect

• Registration data: email, first and last name, date of birth, password (we don't store it: we keep only a non-reversible cryptographic hash, generated with scrypt and a random salt, from which the password cannot be recovered).
• Model data (for those creating a profile): stage name, biography, city, photographs, declaration of adult age and ownership of the content; in the profile's private vault, first name, last name, date of birth and phone number.
• Photographer profile: if you add them, your profile photo and your Instagram profile.
• Consents: we record date, document version, language and IP address of when you grant or withdraw consent, as proof under the GDPR; for signatures with a code we also record the email address the code was sent to, the time it was sent and signed, the browser's technical data (user agent) and the fingerprint (hash) of the signed text.
• Usage data: technical logs, members-area activity (e.g. logins, requests) and page visit counts; for 90 days visit counts are linked to your account if you are signed in, or recorded in pseudonymised form if you browse without an account, then only aggregate figures remain.
• Browsing and analytics data: see the Cookie Policy (cookie-free traffic statistics with Plausible).
• Payments: for the Supporter subscription we do not store credit-card data; transactions (bank transfer, coupon and PayPal) take place through the respective providers.
• Phone: your number, if you add it to your photographer profile (it is required to sign up for live events and to ask a model to come to your city), enter it in the private vault of your model profile (where it is mandatory) or in the account recovery form.
• Shutter assistant: your conversations with the assistant and the related data, described in section 7.

3. Purposes and legal bases

• Provide access to the members area and requested services — performance of a contract (Art. 6.1.b).
• Publish a model's promotional profile — consent (Art. 6.1.a), withdrawable at any time.
• Send service emails (verification, password reset, invitations, confirmations) — contract / legitimate interest.
• Send the newsletter, if requested — consent (Art. 6.1.a).
• Measure traffic on an aggregate basis — legitimate interest (Art. 6.1.f) for Plausible's cookie-free statistics, which do not identify visitors, and for our internal counts of visits to pages and profiles (described in section 2), used to understand which pages people find interesting.
• Comply with legal obligations (tax, accounting) and handle disputes — legal obligation / legitimate interest.
• Answer your questions through the Shutter assistant, improve it and check that it is used properly — performance of the requested service / legitimate interest (Art. 6.1.b and 6.1.f; details in section 7).
• Crediting a model with the sign-ups that come from her personal link (referral programme) — consent (Art. 6.1.a) to the wf_ref cookie, which we ask for with the cookie banner and you can withdraw at any time from the «Cookie preferences» link; the cookie is described in the Cookie Policy.
• Protecting the site and accounts (security logs, login attempts, detection of suspicious logins, anti-bot checks) — legitimate interest of the controller in platform security and in preventing abuse and fraud (Art. 6.1.f; Recital 49 GDPR).
• Shootout events: to organise the Shootout events you sign up for, your profile photo is seen by the models in your sessions, the Masters you book and the organisers, and anyone signed up for the same event can find you by searching your exact surname and see your name and surname. The legal basis is our legitimate interest in organising the event and helping participants recognise each other (Art. 6.1.f GDPR); you can object by writing to the address given in section 13.

4. Newsletter and communications

If you subscribe to our newsletter, we process your email address (and, where provided, the name you give us) to send you newsletters and updates about events, workshops, video courses and platform news. This is a standalone purpose, separate from creating an account: you can have an account without receiving the newsletter, and subscribing is not a condition for registering or using the site. Legal basis: your freely given, specific and informed consent (Art. 6(1)(a) GDPR).

How we collect consent: subscription uses double opt-in; after you indicate you wish to receive the newsletter we send an email with a verification code/link, and the subscription is completed only once you confirm the address. Frequency: occasional mailings, no fixed schedule. Sending provider: Brevo (Sendinblue SAS, Paris, France, EU), acting as a data processor on our behalf. How to unsubscribe: you can withdraw consent at any time, without reasons and without disadvantage, by writing to maxu@workshopfotografico.com (and, on periodic mailings, via the unsubscribe link at the bottom of the email). Withdrawal does not affect the lawfulness of mailings sent before it. We keep proof of consent and of any withdrawal for the period stated in the Retention section.

5. Contacts between models and photographers (community feature)

The platform offers a feature that lets photographers and models get in touch. It is based entirely on the explicit consent of those who take part: no contact detail becomes visible to other users unless you have first actively chosen to make it visible, and every choice can be revoked at any time.

Photographers: if you enable «Allow models to contact me», you choose which channels to make visible (Instagram and/or email). Your phone number is NEVER shown through this feature. Models: for each piece of profile information (base city and tour, Instagram and website, email, availability for topless/nude shoots, public portfolio) you independently choose which category of users may see it: everyone (including guests), registered users, Supporters only, or no one; you show the reserved portfolio to Supporters only or to no one. The base city and the cities of the tour stops also show in the models directory and in the alerts to local photographers. A time-limited private «VIP» link is also available (valid for 24 or 48 hours, revocable before expiry) to show otherwise-reserved information to a specific person for a limited time. At Shootout events, what you choose for the event between topless and fine-art nude (or «Portrait - Glamour», if you choose neither) appears under your name on your model profile for the event, visible to everyone, and on the screens where the event's photographers book; until you choose, what you indicated in your profile appears. It applies to that event and we record it like the other consents. You can change it from your Shootout area until your first booking; after that it stays the same for the event, even if you change your profile. To withdraw it, write to maxu@workshopfotografico.com.

Shootout events: event by event, you choose whether to introduce yourself to the other photographers at the event, showing your name, surname, photo and Instagram. By sending or accepting a friend request you show your friend your name, surname, photo and Instagram, and each of you sees the other's sessions at that event; after the event your friend keeps seeing your name, surname, photo and Instagram until either of you removes the other. We record these choices like the other consents and you can withdraw them from your area: the introduction from the event's Friends menu, friendships with «Remove friend».

Legal basis: the data subject's explicit consent (Art. 6(1)(a) GDPR; for availability for artistic nude shoots and for reserved-portfolio content, Art. 9(2)(a) GDPR also applies). Location data and «Model on Tour» notifications: we use the city/location you provide (base or tour stop) to calculate geographic proximity. When a model publishes a tour, photographers within a base radius of the destination may receive a notification; the radius is doubled if that model is among their favorites. The radii are configurable. This is purely a distance calculation: no selection, sorting or ranking algorithm, and no automated evaluation of individuals. The model's own search for photographers works the same way. To find your city you can type its name (the search uses the Open-Meteo service) or, if you allow it in your browser, use your device's location: in that case the coordinates are sent to OpenStreetMap (Nominatim) to find the name of the place, and we save the name of the place together with the coordinates detected by your device, i.e. the spot where you were at that moment.

Withdrawal: you can change or revoke your visibility settings at any time from your panel, with immediate effect. Consent records: for transparency and traceability we record consents, with date, time, document version, language and IP; visibility preferences apply in the latest version you chose. What we do NOT do: we do not keep or publish any record of «who viewed whom». Responsibility for using others' data: any use of other users' data outside the platform (e.g. unsolicited messages, marketing or other aims) is the sole responsibility of the person using it, who in that case independently acts as data controller.

6. Artistic and nude imagery (sensitive content)

The website hosts artistic, glamour and fine-art nude photography of adult persons. While this is neither an adult website nor pornographic content, we are aware that these images concern a sensitive context and that depicting the body requires particular care and respect. The images in themselves do not automatically constitute «special categories of data» (Art. 9 GDPR); however, given their nature, as a precaution we adopt reinforced protection and access-control measures.

Consent and release: each model profile is created voluntarily by the data subject herself, who declares she is of legal age and holds the rights to the content she uploads. Publication is based on her explicit consent, collected through the image-rights release and, for nude images, through a dedicated, separate checkbox in the model's panel. Each consent is recorded with date, version, language and IP, for evidentiary purposes. Photo categories and access: photos are split into public (no nudity) and reserved portfolio (which may contain artistic nudity); the reserved portfolio is visible only to the users the model chooses (e.g. Supporters only), with the option of a time-limited private VIP link (24/48 hours). Withdrawal and removal: the model can change visibility or withdraw consent at any time, with immediate effect on the public part; upon a removal request we remove the images from the public part immediately and proceed with permanent deletion from storage within 30 days (see the Retention section).

Measures against scraping and unauthorized downloading: we adopt technical and organizational measures to reduce the risk of copying or mass extraction (the Cloudflare Turnstile anti-bot check on the site's forms, access to reserved content limited to Supporters only, and an express prohibition, in the Terms, on downloading or redistributing the images). However, no technical measure can guarantee absolute protection against unlawful use by third parties. A dedicated page describes the publication terms and the data subjects' rights in detail: model release.

7. Shutter, the artificial intelligence assistant

The site offers Shutter, an assistant based on artificial intelligence that answers questions about the site, the workshops, the models and the events. Using it is optional: the site works without it, and you can hide Shutter at any time. Shutter is an artificial intelligence and can make mistakes: the official documentation on the site always prevails. Its answers are for information only: sign-ups, bookings, payments and settings are handled on the site's pages.

What data it processes
• Conversations: the questions you write and Shutter's answers, with the page you are writing from, the language, date and time, any rating you give (👍/👎) and the notes of the automatic checks on the answers.
• Who is writing: if you have an account, a link to your account, your role on the site (for example photographer, Supporter, model, event participant) and the events you take part in; if you write without an account, a pseudonymous code (hash) calculated with a secret key from your IP address, browser and the date. Shutter does not store your IP address in readable form.
• Usage counters: the number of messages per day, per person and per internet connection (using a pseudonymous code derived from the IP address), and the amount of text processed (tokens) per day per person, to apply usage limits and prevent abuse. Shutter's general statistics are anonymous counts.
• Anti-bot check: if you write without an account, at your first question and then about every half hour while you keep writing, a Cloudflare Turnstile check verifies that a person is writing; for this, Cloudflare receives your IP address and technical browser data.
• Events: if you take part in an event, for practical questions Shutter uses the event guide and the information in your panel (times, places, sets and people in your sessions). To a model it gives the names of the photographers and Masters in her sessions, i.e. the names they registered with on the site; to a photographer it gives the models and the Master he chose, and only the number of other photographers. So if you are a photographer or a Master signed up for an event, your name may reach Anthropic when a model in your session, or a photographer who chose you as Master, asks about their own sessions. The only contacts Shutter passes on are those MaXu wrote in the event guide; participants' emails, phone numbers and financial figures are excluded.

What the artificial intelligence provider receives: to prepare the answer we send Anthropic (see section 9) your question, the latest exchanges in the conversation, your role on the site (visitor, photographer or model), the site's public texts and the data of the page you are looking at; if you take part in an event, also the event guide and your sessions, with the names of the people described above. Your name, email and identifier stay on our server. Anthropic acts as a data processor: it stores the data in the United States and may also process it in other countries, with the safeguards described in section 11; under the contract it keeps the data out of the training of its models and keeps it for up to 30 days (up to 2 years for content it flags as a breach of its usage policies, up to 7 years for the scores of its safety checks).

Purposes and legal bases
• Answer your questions and, if you ask, pass them on to MaXu — performance of the service you requested (Art. 6.1.b) if you have an account; if you write without an account, legitimate interest of the controller in answering visitors who are considering the site's services (Art. 6.1.f).
• Statistics, improvement and oversight: understanding how Shutter is used, improving its answers and checking that they are correct, including MaXu reading the conversations — legitimate interest of the controller in offering a useful, accurate and safe assistant (Art. 6.1.f). In balancing this interest against your rights we took into account the 30-day retention, reading being reserved to MaXu and Anthropic receiving questions without your name, email or identifier; on request we will give you the details of this assessment.
• Security, usage limits and abuse prevention, including against automated programs — legitimate interest (Art. 6.1.f).
• Telling event participants, when they ask, who is in their sessions (photographers and Masters for a model, the chosen Master for a photographer) — legitimate interest of the participants and of the controller in organising the event (Art. 6.1.f): these are names each of them already sees in their own panel.

Who reads the conversations: only the controller (MaXu), from the admin panel, for the purposes listed above. Next to each conversation he sees the account name (or the email, if the name is missing); for people writing without an account he sees only «anonymous». Retention: conversations are kept for 30 days and then deleted automatically; questions passed on to MaXu and usage counters follow the periods set out in the Retention section.

If you forward a question to MaXu and he replies, we let you know with a notification and an email, and you'll find the answer inside Shutter. If you write without an account you can leave an optional email: we use it only to send you the answer and delete it as soon as the answer is sent, or together with the question, within 90 days, if no answer comes.

Right to object: you can object at any time to the processing based on legitimate interest (reading conversations for statistics, improvement and oversight; usage limits and abuse prevention) by writing to maxu@workshopfotografico.com. When you object, we delete your conversations and the questions passed on to MaXu, unless there are overriding legitimate grounds such as ongoing abuse.

Access and deletion: at the same address you can ask for access to your conversations or for their deletion. If you have an account, we find them through your account; if you wrote without an account, tell us the day, the approximate time and the text of your question: this is how we can find them.

A tip: in your questions, write only what is needed. Please leave out information about health, sex life or sexual orientation, as well as other people's personal data: Shutter answers just as well without it.

Internal analysis tools: to analyse how the site is doing, the controller uses an artificial intelligence assistant (Anthropic) reserved to him. To answer his questions the assistant reads, read-only, the site data it needs (for example sign-ups, events, payments and statistics) and sends it to Anthropic. It never reads passwords, access codes or models' contact details. Legal basis: the controller's legitimate interest in running and improving his business (art. 6.1.f). The assistant's conversations are kept for 30 days.

8. No automated decision-making or profiling

We do not carry out automated decision-making that produces legal effects concerning you or similarly significantly affects you (Art. 22 GDPR). We do not perform profiling for advertising purposes: we do not automatically analyse your behaviour to build commercial profiles, predict preferences or personalise ads. The «Model on Tour» geographic notifications do not constitute profiling or automated selection: they are limited to a proximity calculation (the distance between one location and another). You can turn off these notifications at any time from your panel, with no impact on your use of the rest of the platform. The Shutter assistant follows the same principle: it answers questions, shows only what your role on the site already allows you to see, and its daily usage limits are simple technical measures.

9. Data recipients: providers and other controllers

We do not sell or transfer your data. To provide the service we rely on the providers listed below. Unless otherwise stated, providers qualified as «data processors» act on our behalf under an agreement pursuant to Article 28 GDPR.

LiveStage is not included in this list: it is a third-party, external platform with which there is no direct data exchange (see the next section). This list may be updated over time; for the current version write to maxu@workshopfotografico.com.

In case of damage: if damage to people or property occurs during a live event, the data needed to handle it may be disclosed to the injured party, the location manager, the insurer, lawyers and the authorities.

10. LiveStage (streaming events) — third-party platform

LiveStage is a platform external to and independent from WorkshopFotografico.com. WorkshopFotografico.com does not operate, and is not operated by, LiveStage; it does not control the services offered through that platform and does not directly receive from, or share with, LiveStage any personal data of users for the purposes of registration, access, payment, streaming, chat, or management of releases.

Any use of LiveStage takes place outside workshopfotografico.com and under the sole responsibility of the user and of the LiveStage platform, in accordance with the terms and notices made available by LiveStage itself.

11. Data transfers outside the European Union

Your data is processed primarily within the European Union: server and database hosting is in Germany (Hetzner, Neon database in Frankfurt), image storage is in Western Europe (Cloudflare R2), emails are sent through a French provider (Brevo) and traffic statistics are handled by an Estonian provider with servers in Germany and Finland (Plausible). In some limited cases the use of third-party services may involve a transfer to countries outside the EU/EEA; when this happens we ensure it is covered by an appropriate basis under Chapter V of the GDPR (Articles 44-49): an adequacy decision, participation in the EU-US Data Privacy Framework (DPF), or Standard Contractual Clauses (SCC), where appropriate with supplementary measures.

The Shutter assistant, the internal analysis tools and the biography translations use Anthropic: the questions and texts sent are stored in the United States and may also be processed in other countries where Anthropic and its sub-processors operate, on the basis of the Standard Contractual Clauses (modules 2 and 3) in its data processing agreement. Place searches use OpenStreetMap (United Kingdom) and Open-Meteo (Switzerland), countries covered by an adequacy decision; Open-Meteo is responsible, as an independent controller, for its own servers in North America.

In addition, Cloudflare's Turnstile anti-bot check runs on global infrastructure: where data transits outside the EU, the transfer is governed by the SCC. You may request a copy of the safeguards adopted by writing to maxu@workshopfotografico.com.

12. Retention

We retain personal data only for as long as necessary for the purposes for which it was collected and to comply with legal obligations:
• Active account: for the entire duration of the relationship, until the account is closed.
• Closed account: we erase or anonymize data within 30 days of the request, except data we must keep by law and data with its own deadline set out below (security logs, proof of consents and signatures, questions passed on to MaXu, Shutter usage counters), which is deleted when that deadline is reached.
• Tax data and invoices: 10 years (Art. 2220 Italian Civil Code and tax law).
• Security and activity logs: 90 days, for security, abuse prevention and diagnostics. In the activity log, after 90 days (or immediately, if the account has been deleted) we remove emails, names and cities: only the type of action, the date and internal references remain.
• Models' images after a profile is removed: immediate removal from the public part; permanent deletion from storage within 30 days (technical propagation across backups and CDN).
• Consents (acceptance of the Terms and Privacy Policy, visibility preferences, releases, events' terms of participation, newsletter): kept while they are in force. After withdrawal, or after the account or model page is deleted, we keep only the proof (type, version, date and time, language, IP, email and, for model pages, the stage name) for 5 years, the limitation period, and then delete it.
• Live events' terms of participation and signatures: by way of exception to the previous point, we keep the proof of live events' terms of participation and of signatures for 10 years from the last day of the event, and in any case until the end of any dispute.
• Traffic statistics (Plausible): aggregate statistics only, with no data that identifies visitors; our internal visit counts are kept for 90 days (linked to your account if you are signed in, otherwise pseudonymised), then aggregate only.
• Conversations with Shutter: 30 days from the start of the conversation, then automatic deletion; earlier, if your account is deleted. At Anthropic: up to 30 days (up to 2 years for content flagged as breaching its usage policies, up to 7 years for the scores of its safety checks).
• Conversations of the internal analysis tools: 30 days, then automatic deletion. At Anthropic: up to 30 days (up to 2 years for content flagged as breaching its usage policies, up to 7 years for the scores of its safety checks).
• Questions passed on to MaXu: up to 90 days while pending and 30 days after they are answered. If your account is deleted they stay until the same deadline, with no remaining link to it, for the controller's legitimate interest in completing their review (Art. 6.1.f); if you prefer us to delete them straight away, write to us quoting the text of the question. If a question becomes one of the site's FAQs, MaXu rewrites it in his own words.
• Shutter usage counters: 90 days, like the security logs.
• Verification and password-reset codes: deleted 7 days after they expire (they are valid for 24 hours at most).
• Account recovery requests: 90 days after the request is closed, 12 months at most.
• Model applications not accepted: 12 months.
• Newsletter: the list of who received each campaign is kept for 24 months; the list of people who asked to stop receiving emails is kept as long as it is needed to respect that choice.
• Administrator notifications about other people: 90 days after they are read; the one about an account being closed, 30 days.
• Shootout events: friend requests that were not accepted are deleted 30 days after the last day of the event; the log of surname searches after 24 hours; friendships stay until either person removes them or closes their account.
At the end of the period, data is erased or irreversibly anonymized.

13. Your rights

You may at any time exercise your rights of access, rectification, erasure, restriction and portability, and withdraw any consent given, by writing to maxu@workshopfotografico.com. You also have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

Right to object (Art. 21 GDPR): you can object at any time, at the same address, to the processing based on our legitimate interest: traffic statistics, security and abuse prevention, service emails based on legitimate interest, the Shutter assistant (see section 7), and the organisation of Shootout events: your profile photo seen by the people in your sessions and the surname search among participants (see section 3). From then on we stop processing your data for that purpose, unless there are overriding legitimate grounds or the data is needed to establish, exercise or defend legal claims.

14. Minors

The site publishes artistic photography, including fine-art nude photography — a cultural form on a par with that exhibited in museums. As a simple precaution, access is reserved for adults; we do not knowingly collect data of persons under 18.

15. Changes

We may update this notice; significant changes will be indicated on the site together with the new update date.